Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition

Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition

Author: Peter H. Blessing

Publisher: Kluwer Law International B.V.

Published: 2020-03-10

Total Pages: 7048

ISBN-13: 9041190732

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Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon


Langer on Practical International Tax Planning: Focus on tax planning

Langer on Practical International Tax Planning: Focus on tax planning

Author: Denis A. Kleinfeld

Publisher: Practising Law Inst

Published: 2000

Total Pages: 1735

ISBN-13: 9780872241282

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Examining more than 50 tax-advantaged territories around the world, PLI's Langer on Practical International Tax Planning gives you the current knowledge and savvy advice you need to help clients capitalize on ripe tax havens and financial centers.


Internal Revenue Service Practice and Procedure Deskbook

Internal Revenue Service Practice and Procedure Deskbook

Author: Ira L. Shafiroff

Publisher:

Published: 1998

Total Pages: 1198

ISBN-13:

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Unless you have worked for the IRS, it's pretty hard to get a handle on the inner workings of this massive governmental agency and use that information to most effectively represent your clients. The new third edition of the Internal Revenue Service Practice & Procedure Deskbook -- written by a former IRS Tax Examiner - puts valuable insider tips to work for you, offering proven techniques and practice-oriented advice for resolving IRS disputes. Now published in an easy-to-use looseleaf format, the new edition of the Deskbook is fully updated to reflect and analyse the numerous changes in federal tax procedure, including analysis of the IRS Restructuring and Reform Act of 1998, Taxpayer Bill of Rights 2 and 3, and the Taxpayer Relief Act of 1997. In addition, Internal Revenue Service Practice & Procedure Deskbook contains a substantial appendix which includes sample forms and letters (such as sample protest letters to the Appeals Office and a model Tax Court petition) as well as the official IRS Audit Handbook.


International Tax Havens

International Tax Havens

Author: Anthony Sanfield Ginsberg

Publisher: Butterworth-Heinemann

Published: 1990

Total Pages: 200

ISBN-13:

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This is a book about how to avoid paying tax, which the author contends is legal.


Offshore Tax Havens

Offshore Tax Havens

Author: United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight

Publisher:

Published: 1979

Total Pages: 404

ISBN-13:

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A VAT/GST Model Convention

A VAT/GST Model Convention

Author: Thomas Ecker

Publisher: IBFD

Published: 2013

Total Pages: 493

ISBN-13: 908722172X

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Given the increasing problem of double taxation concerning value added tax (VAT)/goods and services tax (GST) and the resulting constraints to international trade, it is time for the international community to take action. This book analyses the phenomenon of VAT/GST double taxation and possible remedies. VAT/GST treaties would be one of them. But how should one design a VAT/GST treaty? To what extent do existing income tax treaties already apply to VAT/GST? Can income tax treaties simply be extended to VAT/GST or is there a need for a separate, independent VAT/GST treaty? Can the concepts, functioning, and structure of income tax treaties be used for VAT/GST purposes? What are possible alternatives? What should the scope of a VAT/GST treaty be? How can taxing rights be allocated between the parties to a treaty?